It is a basic requirement of approval that traders operate in a reasonably transparent way. Where traders appear to lack transparency, either in their organisation or their dealings with excise goods, officers must question and consider whether the trader’s activity compromises our ability to gain an acceptable level of assurance or represents a higher than acceptable revenue risk. If either is the case, officers should seek an explanation from the trader. If the explanation is not credible or satisfactory, officers must consider whether continued approval is justified given any risks identified. See X99 Approvals and Registrations guidance for further information.